Illogical Cloud Positivism
Last we learned, Peter Coffee was Director of Platform Research for salesforce.com. He also blogs on their corporate weblog, CloudBlog, a blog that promises “Insights on the Future of Cloud Computing”.
He has a post up from last week that called “Private Clouds, Flat Earths, and Unicorns” [link to http://cloudblog.salesforce.com/2010/07/private-clouds-horses-and-unicorns.html no longer works] within which he tries to “bust some myths” about Cloud Security. Now most of the time, corporate blogs are almost always light on content, but at least most of the time they are banal, emasculated vagaries that can neither be too stupid nor particularly insightful. Well, not this one.
This blog post is so dangerously filled with complete and utter cowpie that I could not but respond here – it is fundamentally contrary to the concerns James Arlen and I wrote for the IRM chapter of the CSA document.
It is a completely Cloud-tarded article.
WHAT? A SAAS PROVIDER RAILING AGAINST PRIVATE CLOUDS?!?! I CAN’T BELIEVE IT!!!
First, Peter makes the assertion that when IT managers are surveyed and state a strong preference for “private clouds” and that this is a desire, not their choice, and subsequently ridicules IT managers for having that desire. His claim is that:
“To have physical possession of the data, you also have to own and maintain the data storage hardware and software.”
This is a dangerous assertion for a cloud provider to make. The semantic game he’s playing here is around the word “possession”. I’ll agree that it is impossible to have physical possession without ownership of the infrastructure. Fine. But this is NOT what security and responsibility (both ethical and legal responsibility) in cloud computing is about. Cloud Risk Management is not about possession, it is about custodianship. If I put credit card numbers in your (his) cloud, I am still, in the eyes of class action lawsuits at least, it’s custodian. Looking at all forms of loss associated with a data breach, there is no pure, 100% transfer of risk. And *this* is the problem IT managers face.
COFFEE’S NAIVE IMPACT MODELING
A desire for security (more below) operations stems solely from the fact that risk is not completely transferred. What do I mean? If my bank puts my banking data in Salesforce.com and there’s a breach, yes – I’m going to be mad at Salesforce. But I’m going to pull my money (and it’s earning potential) out of my bank because some Cloudtard over there decided that this was a good idea.
In other words (use ISO 27005, FAIR, VERIS, whatever) Primary Loss Factors are only half the impact model. And maybe the Cloud Provider owns some of that loss, maybe they don’t. Secondary Factors are still borne solely by those that use the cloud provider.
BEING GOOD AT OPSEC IS A CRITICAL COMPONENT IN RISK MANAGEMENT
“If you have operational control of the infrastructure you have to employ and supervise a “team of experts” who spend most of their time waiting to respond to critical but rare events.”
One has to but wonder how often Peter talks to his own OpSec guys. I imagine (sincerely hope) that the CIRT team at Salesforce absolutely cringed when they read this. Indeed, my sympathies go out to you, Your Supreme Galactic Director Of Platform just called you a mostly useless operating expense, and you may have a little internal selling to do.
That aside, anyone who has heard me speak for the last year knows the stress I put on understanding your OpSec capabilities as a component of managing risk. I won’t rehash those presentations (they’re online – use The Google) but both understanding the Cloud Providers capabilities and your ability to interact with them – that is the crux of managing risk in the cloud.
ILLOGICAL CLOUD POSITIVISM
“Security in cloud services can be constructed, maintained and operated at levels that are far beyond what’s cost-effective for almost any individual company or organization.”
The irony of this quote, of course, is that his linked supporting evidence is SalesForce’s statement of ISO 27001 compliance. ’nuff said.
But in regards to the actual argument, the answer is: “maybe”. If InfoSec is the study of the collision of multiple complex systems, and the cloud provider has a much more complex system to manage than you do on your own, the answer must be “maybe”. To support such a statement we must identify models that are informative about cost to secure per $. I haven’t seen much research around this, and certainly Coffee doesn’t link to any.
COMPLIANCE ISN’T A “ROLES” AUDIT
“The discipline and clarity of service invocations in true cloud environments can greatly aid the control of access, and the auditability of actions, that are dauntingly expensive and complex to achieve in traditional IT settings.”
I honestly have no idea what this means. I take it that he’s saying that proof of access control and audit evidence is easier to gain just by casually tossing an email in the direction of your SaaS buddy. But in terms of regulatory compliance (PCI DSS, HIPAA, OTHER ALPHABET SOUP) my experience is vastly different.
HEY, TECHNOLOGY IS TECHNOLOGY, RIGHT?
“Customization and integration of cloud services are neither intrinsically better nor inherently worse than the capabilities of an on-premise stack.”
This, of course, viewed in the context of the top two points Coffee makes, for the purposes of risk management, are statements with contradictory implications. Let me some up what Peter says to me when I read this article:
“The cloud is easy to use. The cloud is easier to secure. The cloud is friendly to auditors.” and “The cloud is neither better nor worse than securing data on site.”
I’M STILL OK WITH THE CLOUD
With my years of SMB F.I. audit/PenTest experience, I don’t disagree that cloud computing may make sense from a risk management standpoint. I’ve been appalled at times about the one guy in the middle of nowhere Midwest whose in charge of $200 million in credit union/pension fund assets. The other thing to remember is that in fact, in many ways these SMB FI folks have been offloading financial machinations to partners for years – they are already “cloud users” by some informal lose definition. But it’s an awfully cavalier attitude Mr. Coffee takes here with us making these assertions, esp. with no real supporting evidence. Welcome to the NewSchool, Peter Coffee. In God We Trust, everyone else brings data.